F.N.P.S. President's Statement on Proposed Surplus Lands

The mission of the Florida Native Plant Society is to
promote the preservation, conservation, and restoration of
the native plants and native plant communities of Florida.

April 12, 2015

Robert Beltran, Executive Director
Southwest Florida Water Management District
2379 Broad Street
Brooksville, Florida 34604-6899

Subject:  Comments on Proposal to Surplus District-held Conservation Lands

Dear Mr. Beltran:

The Florida Native Plant Society (Society) recognizes that the Southwest Florida Water Management District (District) is a critically important participant in Florida’s land conservation efforts. We hope you recognize the Society to be an especially supportive and engaged stakeholder given our regular participation on land management review teams, the assistance several of our local chapters have provided by conducting plant surveys on District lands, and the various other forms of support we have provided over the years.

We have evaluated the lands proposed for surplussing as part of the ongoing Biennial Assessment and disagree strongly with inclusion of a number of the parcels. The District has not shared any information on the assessment process that was used to assemble the list, and we believe such information must be shared with the public before a well-conceived proposal can be submitted for consideration by the Governing Board.

While we believe the surplussing of lands that truly lack conservation value is a responsible course of action, we also believe surplussing decisions must be based an expansive interpretation of what constitutes conservation value, and the adoption of a long-range view. The tremendous investment the public has made in funding these acquisitions, and will continue to make to ensure the lands are properly managed, demands nothing less.

The following discussion summarizes the results of our evaluation for several project areas. The comments are representative of the expansive interpretation and long-term view we espouse, and that we believe is lacking from the District’s proposal. We conclude the letter with a table that summarizes our position on each of the parcels identified in the District’s proposed list.

Green Swamp Wilderness Preserve (GSWP)

The GSE-1, GSE-2 and GSE-3 parcels (left) are proposed to be surplussed with a conservation easement retained over them. Decisions on whether relinquishing fee title ownership is justified should be based first and foremost on whether the natural and societal values of a subject parcel can be conserved effectively through less-than-fee ownership. “Working landscapes” that provide income for a fee-title owner while conserving natural resources that benefit the public will be an essential part of the “mix” in Florida’s efforts to create a viable, sustainable network of conservation lands. The upland portions of GSE-1 have been converted to improved pasture, it is contiguous with other lands protected through easements, and is within an approved Florida Forever project area that has identified easements as a suitable mechanism for protection. We believe it may be appropriate to sell fee-title to GSE-1, provided a highly restrictive easement is retained that would preclude conversion of unaltered areas, logging in wetlands, extractive uses or subdivision, and that limit future uses to agricultural or silvicultural uses that would be compatible with conservation objectives for the Green Swamp. It should also include a requirement that invasive plants be controlled and any fire-maintained habitats be subjected to burns.

However, the District should not consider GSE-2 and GSE-3 as surplus parcels given their size (111 and 227 acres, respectively), relatively unaltered condition, contiguity with the main body of the GSWP, frontage on the Van Fleet State Trail (>1.5 miles total) and exceptional habitat values. Both parcels include pine flatwoods habitat and isolated wetland systems. Flatwoods have been designated an Under-Represented Natural Community by the Florida Forever Conservation Needs Assessment (FFCNA), and both parcels are within a Priority 2 Ecological Greenway. Listed species that are potentially present on these lands, based on available data, include the Eastern indigo snake, celestial lily, red-margined zephyr lily, swamp plumed polypody, cutthroat grass and gopher tortoise. The forested wetland serves as potential nesting or roosting habitat for swallow-tailed kites. And finally, GSE-3 encompasses a portion of main stem of the Withlacoochee River in the uppermost headwater reaches of the river. If these lands were not already protected through fee-title public ownership, they would be outstanding candidates for such protection. It is difficult to fathom how they could be identified as possible surplus parcels. 

We applied the same basic evaluation criteria to the GSW-3 and GSW-4 parcels (left). Although pine plantation accounts for much of the GSW-3 land area, the parcel supports a diverse mix of habitat types and maintains a linkage between the GSWP and Colt Creek State Park. The plantation area should be targeted for future habitat restoration and fee-title ownership of this 326-acre parcel should be retained. Much of GSW-4 has been converted to improved pasture and it represents a transitional zone between the core habitat of the GSWP and the surrounding working landscapes (i.e., ranches) that supplement the habitat conserved under public ownership and buffer it from surrounding land uses. It could be appropriate to consider surplussing GSW-4, provided it would continue to be conserved under a highly restrictive easement. However, the value of land encumbered by such restrictions may be extremely limited in the private market. It could be more cost-effective for the District to lease large, modified parcels like GSW-4 for cattle grazing or haying, or engage in revenue-generating silviculture in the pasture areas, rather than relinquish ownership and the control it provides. Such a cost-benefit analysis should be part of the District’s assessment, yet there is no evidence that such factors received any consideration.

Annutteliga Hammock

“Mega-Parcel” projects like Annutteliga Hammock are incredibly challenging. They require a long-term commitment and patience. We believe a decision to surplus the large number of small and largely disjunct parcels acquired through this project is premature. There is also a 160-acre parcel in the northwest corner of the project area that has superlative stand-alone conservation value, yet it is proposed for surplus. As illustrated by the series of maps below, the Annutteliga Hammock project seeks to conserve a land area with extraordinary natural significance. Recharge rates are as high as any recorded in the state. The corollary of this is that the vulnerability of the Floridan aquifer to contamination equally high – with the main headwater springs of the Chassahowitzka River less than 2 miles to the northwest. Minimizing development in this area, and the threat of groundwater contamination that it poses, should be factored into any decisions to surplus lands here. The Priority 2 Ecological Greenway ranking of the GSWP parcels discussed previously is significant; this project is a Priority 1 “Critical Linkage” and represents the last viable opportunity to maintain functional connectivity between the Chassahowitza complex of conservation lands along the coast and the Withlacoochee State Forest to the northeast. 

Lastly, it should be noted the sandhill habitat of the project area is another Under-Represented Natural Community. Listed species known to inhabit the sandhill habitats of the Annuttliga Hammock and adjoining public lands include the Sherman’s fox squirrel, gopher tortoise, Florida mouse, gopher frog, giant orchid, Chapman’s skeletongrass, Florida pine snake, small-tailed snake, and pine pinweed.

Little Manatee River Corridor Southfork Tract

The 57-acre parcel at the southeastern end of the Little Manatee River Corridor project supports a mixture of pine flatwoods, scrubby flatwoods, wet flatwoods and wet prairie habitat. This area of high habitat diversity is contiguous with the eastern boundary of the South Fork State Park and is proximate to a segment of the Little Manatee River. A surplus sale of the parcel would degrade the value of the neighboring lands that the District proposes to retain. Given the parcel’s contiguity with the state park, proximity to the river, and ease of access from the adjoining road, it would make more sense to incorporate the entire tract into the state park. If this parcel was not already publicly owned, it would be logical to pursue its acquisition; as such, there is little apparent logic in proposing to surplus it.

The parcels discussed above, and many others on your list, merit a much more in-depth discussion than we have provided here. For example, we are also especially concerned by the proposal to surplus two parcels within the Halpata Tastanaki Preserve, where the District’s history of habitat restoration and effective land management are achieving great success. That success is clearly illustrated by an observed expansion of the local Florida scrub jay population. These parcels provide an excellent opportunity to expand the population even more through habitat restoration given the xeric soils that underlie them. Indeed, if jays already inhabit these parcels, any actions that exclude them could be considered a taking of a federally-listed species and a violation of the Endangered Species Act. A federally listed plant species – the endangered longspur balm – may also occur on these xeric soils. The Preserve, in combination with the neighboring Ross Prairie State Forest, constitutes the only area of significant core habitat along the entire Cross Florida Greenway, from the Ocala National Forest to the Gulf of Mexico. We believe virtually every acre now under public ownership should be retained.

The District has the staff and other resources to conduct a comprehensive assessment of these lands you hold in trust for the public. The Society does not enjoy the benefit of such resources, yet there is little evidence to indicate that you have conducted an assessment as discerning as ours. We ask that you conduct a scientifically rigorous and transparent evaluation before you finalize the Biennial Assessment. We stand ready to assist you in any way we can, and look forward to continuing our constructive relationship with the District. Thank you for considering our concerns.


Anne C. Cox, President
Florida Native Plant Society

full-size map images can be viewed on the FNPS Flickr page


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